Modern Slavery Statement

Warby Parker is committed to making sure that working conditions throughout our supply chain are safe and that employees are treated with dignity. We require that our products comply with all applicable local and international laws, including laws related to labor, human rights, public health, and workplace safety.

Research by the International Labor Organization shows that there are over 28 million victims of forced labor around the world, and that women and children are particularly vulnerable to this type of abuse. This issue is not new, but legislation in jurisdictions like Canada and California have given companies like ours an opportunity to explain how they address the risk of human rights violations in their supply chains.

This joint report is made by Warby Parker Inc., a Delaware public benefit corporation, on behalf of itself and its wholly owned subsidiaries Warby Parker Retail, Inc., a Delaware corporation, and WPCA Holdings, Inc., a British Columbia Corporation (collectively, referred to as Warby Parker, we, and our), and covers our 2025 fiscal year ended December 31, 2025. This report is intended to demonstrate the steps we have taken to prevent and reduce the risk that forced labor or child labor is used at any step in the production of goods in Canada or elsewhere by Warby Parker or of goods imported into Canada by Warby Parker, in accordance with the requirements of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act. This report is also intended to satisfy the requirements of the California Transparency in Supply Chains Act.

Warby Parker Inc. was incorporated as a Delaware corporation in 2010 and became a Delaware public benefit corporation in 2021 prior to our direct listing on the New York Stock Exchange in September 2021 (NYSE: WRBY). We are a mission-driven, lifestyle brand that operates at the intersection of design, technology, healthcare, and social enterprise. We stand for fun, creativity, and doing good in the world. Every day, our team is focused on our mission to inspire and impact the world with vision, purpose, and style (without charging a premium for it). Our ultimate objective is to provide vision for all.

As a pioneer of the direct-to-consumer model, we design our glasses in-house at our New York City headquarters and sell directly to customers, enabling us to make high-quality, designer eyewear more accessible, with simple, unified pricing starting at $95 including prescription lenses. Since our launch, we’ve expanded beyond glasses to offer comprehensive eye care, including eye exams, contacts, lens enhancements and tech-enabled experiences like Virtual Try-On and Virtual Vision Test, with an aim to make Warby Parker a convenient, one-stop shop for all eye care needs. We operate an integrated, omnichannel platform across digital commerce and our retail stores, all designed to make shopping both convenient and fun.

As a public benefit corporation, we are also focused on positively impacting all stakeholders, and hope to inspire other entrepreneurs and businesses to think along the same lines. We strive to benefit our employees, customers, communities, partners, and the environment by advancing access to eye care and living our core values. Working closely with our nonprofit partners, we distribute glasses to people in need in more than 80 countries globally and in many parts of the United States. To date, over 20 million more people now have the glasses they need to learn, work, and achieve better economic outcomes through our Buy a Pair, Give a Pair program.

We are headquartered in New York City, New York and we operate an additional office in Nashville, Tennessee, in-house optical laboratories in Sloatsburg, New York and Las Vegas, Nevada, and 323 retail stores, with 318 locations in the United States and five locations in Canada¹. Our team includes 4,036 individuals, with 51 employees in Canada². Our Canadian operations are carried out by WPCA Holdings, Inc. and our retail leases, including for our retail stores in Canada, are held by Warby Parker Retail, Inc. Our products are imported from Warby Parker Inc. to WPCA Holdings, Inc. from our in-house optical laboratories or U.S. fulfillment centers to a Canadian retail store or directly to a Canadian customer.

1. ¹ As of December 31, 2025.
2. ² As of December 31, 2025. Includes Warby Parker employees as well as ophthalmologists and optometrists engaged through our P.C. model, but does not include contractors or independent optometrists.

We partner with frame factories, lens and case kit suppliers, distribution centers, optical labs, and freight-forwarding and logistics companies all over the globe. We also rely on our retail locations and in-house optical labs. Our first in-house optical lab opened in 2016 in Sloatsburg, New York, and in 2021, we opened a second optical lab in Las Vegas, Nevada.

In addition to fulfilling prescription eyewear orders, our supply chain also supports contacts, sunglasses, gift cards, and accessories orders; returns fulfillment; and the distribution of all goods. These operations are handled out of multiple fulfillment centers in the United States.

All our frames are designed at our New York City headquarters, and we handpick raw materials and the suppliers who have the talent and skill to bring them to life. These deliberate decisions help us stay true to our original aesthetic vision as well as regulatory and performance results. We work with raw material vendors on proprietary development, in addition to frame suppliers on their production methods and machinery, with the goal of achieving best-in-class performance standards.

We work directly with manufacturers and raw material suppliers so that we can know where and how our products are being manufactured. In 2025, we worked with raw material vendors and frame suppliers in the United States, China, Japan, Vietnam, Italy, Singapore, Thailand, and South Korea. We’ve also built out a team of Warby Parker liaisons based in both South China and Vietnam to support our vendors in those regions, as well as in Japan, in following our manufacturing specifications and identifying which methods are ideal for producing first-rate products. This team now conducts all vendor and product inspections, as well as supports quality engineering further upstream in the product development phase.

Our commitment to accountability starts at the top. The Warby Parker Inc. Board of Directors is composed of people who represent a diverse set of ideas, backgrounds, and experiences. The Board executes its responsibilities for oversight for the effective governance of Warby Parker Inc. with the assistance of three board committees: our Nominating and Corporate Governance Committee, Audit Committee, and Compensation Committee. Our Nominating and Corporate Governance Committee has direct oversight of our efforts and strategies with regard to environmental stewardship, corporate citizenship, and other social and public initiatives, as well as our sustainability reporting. Our management regularly assesses the effectiveness of our compliance program and policies, both internally and with third party assistance, and makes enhancements as needed. Ultimately, we understand the importance of setting the right tone at the top and establishing a strong culture of compliance. The sustainability strategies set by Warby Parker Inc. apply to all Warby Parker entities. Warby Parker entities therefore follow and reasonably rely on the due diligence policies and processes developed and implemented by Warby Parker Inc. across their operations and supply chains. This includes the following policies and procedures in place to prevent and reduce the risk of forced labor or child labor in our business and supply chains:

We maintain a Code of Conduct that applies to all our directors, officers, employees, and business partners that sets forth our policies and expectations on topics including conflicts of interest, compliance with laws, ethical conduct, human rights and responsible sourcing, and bribery and anti-corruption. We provide training on the Code of Conduct and require that all employees review and acknowledge the Code of Conduct on an annual basis.

All directors and employees have a duty to report any known or suspected violation of our Code of Conduct, without fear of retaliation and on a confidential basis if desired. Employees may report issues directly to the Legal Team or anonymously to our independent toll-free third-party ethics hotline by phone or through AllVoices.co. Whistleblower reports, and the results of any investigations, are reviewed quarterly by our Audit Committee. We also require all suppliers to have grievance procedures such as a confidential whistle-blowing policy in place for all factory workers.

We adhere to employment screening procedures for compliance with employment regulations of applicable jurisdictions, including those relating to work eligibility requirements, employment conditions, and appropriate workplace conduct.

We maintain that our products must comply with all relevant local, state, and international laws, particularly those related to labor, human rights, public health, and workplace safety. Our Vendor Code of Conduct outlines our requirements for the fair treatment and compensation of all workers—with which we require all direct suppliers to comply— including that our suppliers adhere to our standards on subjects such as child labor, forced labor, discrimination, harassment and abuse, wages and benefits, overtime, housing, freedom of association, subcontracting, local laws, employee feedback, health and safety, environment, and bribery. Our Vendor Compliance Manual requires that our suppliers worldwide compensate their employees with not only the legal minimum wage where they operate, but a living wage. Our suppliers are required to ensure that compensation for a standard workweek meets or exceeds the minimum applicable legal standards or industry benchmarks, and adequately provides for the basic living needs and discretionary income of supply chain workers and their families. A failure to comply with any of the foregoing standards is considered a material breach of our Vendor Code of Conduct, and we reserve the right to terminate our business relationship with any supplier who violates the terms of our Vendor Code of Conduct.

To ensure that our vendors uphold the requirements set out in our Vendor Code of Conduct, we partner with Verité in Asia and BSI in Europe to regularly audit our direct suppliers’ facilities. These scheduled audits are an opportunity for us to strengthen our relationship with vendors throughout our supply chain and work together on preventing any substandard work conditions. We audit all of our direct suppliers’ factories at least once a year, and each audit is conducted over two or more days, depending on the size of the facility. During an audit and any follow-up visits, Verité’s or BSI’s independent auditors meet with the management of each facility, tour every part of the site, review any pertinent documents, and interview employees at all levels of the organization. After each visit, Verité or BSI generates a numerical score for each facility’s performance. These audits give us a clear and comprehensive picture of employees’ working conditions and allow us to hold our direct suppliers accountable to the specific labor standards outlined in our Vendor Code of Conduct. See the section “Warby Parker Social Compliance Program” for more information about supplier audits.

Our Vendor Code of Conduct applies to all of our direct suppliers. Of course, these suppliers have their own suppliers, who provide them with the various materials and components needed to manufacture our products. As an added safeguard against the threat of human trafficking and slavery, we also audit key indirect suppliers every two years in partnership with Verité and BSI. Key indirect suppliers are the suppliers that we recommend to our vendors and that we spend over $250,000 on each year. This allows us to know whom those suppliers employ and to ensure that they’re also being employed per the labor standards set out in our Vendor Code of Conduct.

To maintain a complete picture of our supply chain and the labor involved in it, we have a zero-tolerance policy toward unapproved subcontractors, facilities, and homework, and we do not work with vendors who are not transparent and cooperative on the matter. Every one of our direct suppliers must be able to prove that its supply chain and all the materials incorporated into our products comply with national and international laws prohibiting slavery and human trafficking. And whenever there’s a difference between the requirements of local law, international law, and our Vendor Code of Conduct, the most stringent standard always applies.

All of our employees are located in the United States and Canada, where we believe there is a low risk of forced labor and child labor. We consider the greatest risk of forced labor and child labor to exist in our supply chains. Our efforts to make sure that our supply chain is free of human trafficking and slavery begin with thoroughly mapping out our direct suppliers, and the secondary suppliers with whom they work. We then regularly work with independent organizations and other brands to assess the risk of forced labor throughout our supply chain (looking at various factors such as each supplier’s location and employee demographics) and tailor our efforts to prevent it accordingly.

Our primary safeguard against human trafficking is simple: We work only with manufacturing partners who share our commitment to ethical labor practices. Compliance with our Vendor Code of Conduct is a non-negotiable precondition to start and maintain any direct business relationship with us. Our Vendor Code of Conduct outlines our requirements for the fair treatment and compensation of all workers, and expressly prohibits specific abusive labor practices. We work with Verité and BSI to ensure that these standards are being met, and members of our own Supply Chain and Product Development teams regularly visit our suppliers’ factories to supplement Verité’s and BSI’s work.

We piloted the Warby Parker Social Compliance Program alongside the independent fair-labor monitoring group Verité in 2012 and formalized it for our direct and key indirect suppliers in 2013. Since then, all Asia-based direct and key indirect suppliers have been screened using those criteria. For our suppliers in Italy, we onboarded the British Standards Institution (BSI) in 2023 to build upon our existing efforts and develop programs that could scale regionally. The BSI team was able to successfully translate our criteria and standards used across Asia to assess the risks and develop the capabilities particular to the Italian manufacturing landscape. With this new partnership, we expanded our audit presence in Italy in 2025 to all active suppliers, even those that fall below our active direct supplier business threshold. After each auditor screening, our auditors (at either Verité or BSI) calculate a performance score and produce a report outlining any open concerns, as well as a management action plan that acts as a guide for any issue remediation and partner engagement. We then get to work with the relevant supplier on executing the action plan—including clear deliverables, timelines, and metrics for success—to remediate issues.

All Warby Parker direct and key indirect suppliers must maintain a score of “Good” or higher, as determined by Verité or BSI. Scores assess three categories—Management System, Labor, and Environmental Health and Safety—and within each, Policy and Procedure, Implementation, and Performance.

Our Product Development team leads the Social Compliance Program, which includes part of the vetting and onboarding process for new suppliers, scheduling audit visits with Verité and BSI, and working with the suppliers to improve on identified issues via management action plans. All our direct suppliers in China, Japan, Vietnam, and Italy are audited in accordance with our program. Strategic indirect suppliers are also audited on a cadence of every two years as long as their scores are “Excellent”. Those with a score below that “Excellent” threshold are audited annually. We define active direct suppliers as product suppliers that we directly transact with and with which we have purchase orders, inventory shipments, and/or payment transactions within the calendar year.

As part of the audit process, Verité and BSI auditors conduct confidential interviews with lineworkers at each factory to gather feedback and data. If a supplier has open compliance issues, they are required to have a Management Action Plan, which they must update monthly to detail findings, remediation action plans, information about completion dates, and responsible management staff. The program requires suppliers to have grievance procedures such as a confidential whistle-blowing policy in place for all factory workers. Our internal teams continuously review the year’s results with the auditing company and discuss opportunities for us to better understand the efficacy of our work managing social compliance in our supply chain. In recent years, we’ve revised our approach to the social compliance visits so that Verité and BSI are working more closely with our suppliers to help them better understand the root causes of open social compliance issues. New operational processes and improvements to management structure have enabled the suppliers to focus on closing open issues and keeping them closed, as well as preventing common problems from even arising.

Our policy against forced labor or child labor is one of zero tolerance. If one of our suppliers were found to be complicit in any form of forced labor whatsoever, we would require the supplier to address and correct the problem immediately, and we would launch an extensive investigation into the issue. We reserve the right to terminate our business relationship with any supplier who violates the terms of our Vendor Code of Conduct. In 2025 we did not identify or have brought to our attention any instances of forced or child labor in our operations or supply chain, and consequently did not take any remediation measures.

To further protect the integrity of our supply chain and the safety of the people working in it, we make a concerted effort to educate our vendors, auditors, and internal teams on the realities of human trafficking and modern-day slavery. We also regularly engage with industry organizations and other companies to stay abreast of the latest developments and regulations surrounding the issue. This makes everyone involved in our supply chain better able to identify and effectively address any potential issues. We also provide training on our Code of Conduct and require that all employees review and acknowledge the Code of Conduct on an annual basis.

Our management along with our Board of Directors regularly assesses the effectiveness of our compliance program and policies, both internally and with third-party assistance, and makes enhancements as needed. We are continuously evolving our approach to prevent and reduce the risk that modern slavery is used in our activities and supply chains.

We are committed to the continuous improvement of our efforts to prevent and reduce the risk of forced labor and child labor in our supply chains. In the coming year, we intend to continue to refine our social compliance audit program in partnership with Verité and BSI, including reviewing and updating audit criteria as appropriate to reflect evolving risks and best practices; further strengthen engagement with our direct and key indirect suppliers on remediation of any open compliance findings; and evaluate opportunities to enhance training and awareness across relevant internal teams involved in supply chain management.

In accordance with the requirements of the Fighting Against Forced Labour and Child Labour in Supply Chains Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report on behalf of the governing body of the entities listed above. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.